1 – General website Information
1.1. This section concerns the way the www.arflex.it website is managed, with regard to the processing of the personal data of the website users. This website describes the activity and the services provided by the company Seven Salotti S.p.A., headquartered in via Pizzo Scalino 1, 20833, Giussano (MB), P. IVA 00703820969, Rea Number: MB – 799065, PEC: email@example.com.
1.3. This policy privacy and the information contained therein only concern the website: www.arflex.it and not any other website which can be consulted through the links contained therein.
1.4. This policy privacy and the information contained therein have the purpose of providing information regarding: the types of data processed, the methods of processing, the data storage periods, the nature of the information and any further relevant aspect of which website www.arflex.it users (also through the alternative URLs www.arflex.com, www.sevensalotti.it and www.sevensalotti.com) must be made aware of by the data controllers, regardless of the purpose of the connection, according to the Italian and the European legislation.
1.5. The website www.arflex.it applies to people aged 16 and over, in accordance to art. 8, par. 1 Reg. (EU) 2016/679. By connecting to the www.arflex.it website and providing its data, the user, which is the data subject, declares to be at least 16 years old.
II – DATA PROCESSING SUBJECTS
2 – Data Controller
2.1. The data controller is the natural or legal person, the public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing of personal data. It shall be incumbent upon the data controller to identify and adopt the appropriate technical and organizational measures to ensure a security level of the personal data processed appropriated to the risk generated by the data processing operations.
2.2. With regards to this website, the data controller is the company Seven Salotti S.p.A. through its legal representative pro tempore, headquartered in via Pizzo Scalino 1, 20833, Giussano (MB); for any clarification or exercise of the user’s rights refer to the following email address: firstname.lastname@example.org.
3 - Personal Data Processor
3.1. The personal data Processor is the natural or legal person, the public authority, agency or other body which processes personal data on behalf of the controller.
3.2. Pursuant to article 28 of the Reg. (EU) 2016/679, the personal data controller may appoint one or more data Processors of the website www.arflex.it among those who may have access to the subjects’ personal data, that is to say third party service providers such as, for example, connectivity providers, hosting, domain registration, couriers, IT companies as well as the software provider that deals with the newsletter forwarding and commercial communications service.
3.3. The list of external Processors, as well as the list of internal Processors of Seven Salotti S.p.A., will be kept up to date and can be requested at any time by writing to the following address: email@example.com.
4 - Place of data processing
4.1. Personal data are recorded and guarded on electronic databases owned by the Controller and the data processing generated by the use of www.arflex.it website is carried out at the Controller’s registered office located in via Pizzo Scalino 1, 20833, Giussano (MB).
4.2. If necessary, the data relating to the newsletter service may be processed by the Data Processor or by the persons who, under the direct authority of the controller or processor, are authorized to process personal data pursuant to art. 4 n. 10 of Reg. (EU) 2016/679 for this purpose at the headquarter referred to in the preceding subparagraph.
III – PROCESSED DATA
5 – Types of data processed and data processing methods
5.1. As all websites, also this website makes use of log files in which information collected in an automated form is stored during users visits. The gathered information is:
5.1.1. URI (Uniform Resource Identifier) Addresses of requested resources;
5.1.2. The request moment;
5.1.3. The method used to submit the request to the server;
5.1.4. The file size obtained in response;
5.1.5. The numeric code indicating the status of the response given by the server;
5.1.6. Other parameters concerning the operating system and the user’s IT infrastructure.
5.2. The information referred to in paragraph 5.1 are automatically processed and collected in an exclusively aggregate form in order to elaborate anonymous statistical information on the website use and to verify the correct website functioning, as well as for security reasons. This information will be processed on the basis of the Controller’s legitimate interests and deleted within 90 days.
5.3. In addition to the information referred to in paragraph 5.1., the following personal data may also be collected from this website:
5.3.1. E-mail address (in case of an information request e-mail sent by the user at the address firstname.lastname@example.org or in case of provision of this data made by the same user, to the Controller or qualified entities during contacts, Fairs or events on order to be included in the newsletter service);
5.3.2. Third parties e-mail address (in case of compilation of the website document sharing form through the inclusion of the address of a subject different from the user and the Controller; in this case the user declares that he has been expressly authorized by the person concerned to provide the Controller this personal data or, however, to be entitled pursuant under the existing regulations on the protection of personal data, declaring to indemnify Seven Salotti S.p.A. from any legal action and/or initiative to protect the interests that the person concerned -as a subject whose the e-mail address has been provided - could put in place in case of unlawful data processing due to lack of consent as well as for any further reason);
5.3.3. User’s Name and Surname (if such data is provided in case of an information request e-mail sent by the user at the address email@example.com or in case of provision of this data made by the same user, to the Controller or qualified entities during contacts, Fairs or events on order to be included in the newsletter service), even if it is contained in the company's name;
5.3.4. Telephone contact and further personal data provided by the user (if this data is provided by the user through an information request e-mail sent at the address firstname.lastname@example.org or in case of provision of this data made by the same user to the Controller or qualified entities during contacts, Fairs or events on order to be included in the newsletter service);
5.3.5. Residence/domicile/headquarter company address (iif such data is provided in case of an information request e-mail sent by the user at the address email@example.com or in case of provision of this data made by the same user, to the Controller or qualified entities during contacts, Fairs or events on order to be included in the newsletter service);
5.3.6. IP Address (Internet Protocol) exclusively for the purpose of the following art. 5.6..
5.4. The personal data referred to in paragraph 5.3. will be processed by the operations indicated in art. 4 n.
2) GDPR, specifically: collection, registration, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of data.
5.5. The personal data referred to in paragraph 5.3, also of an identifying type, are collected and processed in an automated manner for the purposes set out in the following art. 6.
5.6. The information referred to in paragraph 5.1. may be used for the assessment of liability in case of cybercrimes against this website, as is the personal data referred to in paragraph 5.3.6. which are processed exclusively for this purpose.
5.7. For security purposes (anti-spam filters, firewalls, virus detection), information and automatically recorded data referred to in paragraph 5.1. may be used to block attempts of website damage or other harmful or crimes activities, according to the legitimate interests pursued by the Controller or and the current legislation.
5.8. In case of submission of a CV for a possible work opportunity, the data is considered voluntarily provided by the user at the time when the e-mail has been sent. The CV will be examined and, if it will be saved or otherwise stored for future working partnerships, a synthetic information document will be provided from Seven Salotti S.p.A. to the user according to the current legislation.
5.9. The information that website users will make public through the services and tools available are considered provided by the user knowingly and willingly, by exempting Seven Salotti S.p.A. from any responsibility according to the violation of the law. The user has the task of checking whether he has the permission to enter personal data of third parties obtained, published or shared through this website and guarantees to have the right to communicate or disseminate them; It is also up to the user to verify whether he has the permission to include any content protected by national and international rules.
5.10. The data referred to in art. 5.3. may be communicated by the Controller to its agents/retailers if this is requested by the user at the time he sends an e-mail to the address firstname.lastname@example.org requiring information about the resellers from which the goods produced by Seven Salotti S.p.A. can be bought and advertised through this website.
6 - Purpose of processing and data retention period
6.1. The personal data referred to in art. 5.3. collected from the website are used for the following purposes:
6.1.1. Performance of a contract between the user and Seven Salotti S.p.A. or taking steps at the request of the data subject prior to entering into a contract;
6.1.2. Provision of services provided by the website;
6.1.3. Sending of newsletters to the user at the same address provided to Seven Salotti S.p.A. or qualified entities during contacts, Fairs or events on order to be included in the newsletter service;
6.1.4. Sending of advertising and commercial communications on products and services provided by Seven Salotti S.p.A.;
6.1.5. Performance of obligations for compliance with a legal obligation to which the controller is subject (accounting, tax, etc.).
6.2. The preservation of the information referred to in art. 5.1. will be carried out for the period strictly necessary to the attainment of the above-mentioned purposes and in any case not exceeding the termination of the same purposes, with cancellation thereof within 90 days of collection.
6.3. The preservation of the information referred to in art. 5.3 will be carried out for the period strictly necessary to the attainment of the above-mentioned purposes referred to in paragraph 1 and in any case not exceeding the termination of the same purposes except where it is necessary to store them by legal requirement. The data may also be storage for the time required by the Controller or by the Processor designated for establishing, exercising or defending their legal claims in judicial proceedings, within the prescription period of any civil or criminal action taken against them.
6.4. In case of personal data processing based on the user's consent referred to in art. 5.3., Seven Salotti
S.p.A. may storage personal data until such consent will be revoked.
6.5. Data used for security purposes referred to in previous art. 5.7. are stored for the time strictly necessary to achieve this goal and in any case will be deleted within 60 days.
7 – Legal basis of processing operations
7.1. The legal basis for personal data processing referred to in art. 5.3. is the performance of a contract for the purpose indicated in art. 6.1.1. that is entered into under current legislation and in the manner envisaged by contractual terms and conditions of the Seven Salotti S.p.A. contract or the fulfilment of pre- contractual obligations, between Seven Salotti S.p.A. and the user as a result of contacts aimed to evaluate the possible conclusion of a contract between concerning the services provided by Seven Salotti S.p.A.
7.2. The legal basis for personal data processing referred to in art. 5.3. is the performance of a contract for the purpose indicated in art. 6.1.2. that is entered into under current legislation, including, where appropriate, in the manner envisaged by contractual terms and conditions of the Seven Salotti S.p.A. contract
7.3. The legal basis for personal data processing referred to in art. 5.3. for the purpose indicated in art
6.1.3. is the user’s consent (interested) that is expressed at the time of the supply of his contact to the owner or to persons authorized by it during contacts, fairs or events to be included in the newsletter service.
7.4. The legal basis for personal data processing referred to in art. 5.3. for the purpose indicated in art.
6.1.4. is the consent of the user (Subject) that is expressed when he provides his contact to the Controller or to qualified subjects during contacts, Fairs or events on order to be included in the newsletter service.
7.5. The legal basis for personal data processing referred to in art. 5.3. for the purpose indicated in art.
6.1.5. is the performance of a legal obligation to which the Controller is subject to.
8 - Social Network Plugin
8.1. On this website there are also plugins and/or sharing buttons for social networks, in order to allow easy sharing of content on the user's favorite social networks. These plugins are programmed in order not to set any cookies at the time when the user accesses the website www.arflex.it or individual pages thereof, with the aim of safeguarding the user’s privacy. If necessary cookies are set, insofar as required by social networks, only when the user makes actual and voluntary use of the sharing button or of the plugin. It is necessary to emphasize that if the user, accessing the social networks, browses the net having been previously logged in, will have already agreed to the use of the cookies channeled through these social networks as well as to the social networks personal data processing, to which Seven Salotti S.p.A. is completely cleared of any involvement and cannot be held accountable in any way.
Twitter: https://support.twitter.com/articles/20170519-uso-dei-cookie-e-di-altre-tecnologie-simili-da-parte-di- twitter
Google+: http://www.google.com/policies/technologies/cookies Pinterest: https://about.pinterest.com/it/privacy-policy AddThis: http://www.addthis.com/privacy/privacy-policy Linkedin: https://www.linkedin.com/legal/cookie-policy
IV. USER RIGHTS
9 – Subject’s rights
9.1. The art. 13, par. 2 of the Reg. UE 2016/679 lists the user's rights.
9.2. The www.arflex.it website has the purpose to inform the user about the rights referred to in artt. 13, par. 2, b) and d), 15, 16, 17, 18, 19 and 21 GDPR, specifically the right to:
9.2.1. obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed, even if not yet recorded, and their communication in intelligible form;
9.2.2. Get indication about: a) the data source; b) the processing purposes and modalities; c) the logic involved in processing carried out through electronic tools; d) the identity and the contact details of the Controller, of the Data Protection Officer, of the Processors and of the designated Representative referred to in art. 3, par. 1 GDPR; e) recipients or categories of recipient to whom the personal data have been or will
be disclosed or that can become aware of the data as a designated Representative in the territory of the State and as a Processor;
9.2.3. Obtaining: a) the updating, rectification or, if necessary, integration of data; b) the erasure, the anonymization or blocking of personal data processed in violation of law, including those for which the storage is not necessary referring to the purposes of the processing for which the personal data are collected or subsequently processed c) the confirmation that the operations referred to in a) and b) have been communicated, including their content, to those to whom the data have been transmitted or disseminated, except for such fulfilment appears impossible or requires means manifestly disproportionate to the subject's right;
9.2.4. Object completely or in part for legitimate reasons to the data processing even if related to the purpose of data collection;
9.2.5. If applicable, the user has also the rights referred to in arts. 16-21 GDPR (right of rectification, right “to be forgotten”, right of restriction of processing, right to data portability, right of object), and the right to lodge a complaint with a supervisory authority;
9.2.6. Withdraw consent at any time.
9.3. Requests may be addressed to the data Controller, without formalities or, alternatively, using the model provided by the supervisory authority or by sending an e-mail to: email@example.com.
9.4. If the processing refers to art. 6, par. 1, a) GDPR – consent to the processing – or to art. 9, par. 2. a) GDPR – explicit consent to the processing of genetic data, biometric data, data concerning health, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership – the user has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
9.5. Likewise, in the event of law infringement, the user has the right to the right to lodge a complaint with a supervisory authority, which in Italy is Garante per la Protezione dei Dati Personali.
9.6. For a better examination of the user’s (subject) rights, please refer to artt. 15 and following of Reg. (EU) 2016/679 and art. 7 of Italian D. Lgs. 196/2003.
V – NATURE OF CONSENT
10 – Nature of consent
10.1. The provision of personal data referred to in art. 5.3. is mandatory for the fulfilment of the purposes set out in artt. 6.1.1. and 6.1.2.. Any refusal to provide such data causes the impossibility for the Controller to provide the services referred to in art. 6.1.1. and 6.1.2..
10.2. The provision of personal data referred to in art. 5.3. for the fulfilment of the purposes set out in artt.
6.1.3. and 6.1.4. is optional. The subject may also decide not to provide any data or subsequently deny the data processing already provided for these purposes: in this case the Controller will not fulfil the purposes referred to in art. 6.1.3. and 6.1.4.. In this case, the user may continue to make use of the services referred to in the artt. 6.1.1. and 6.1.2..
10.3. The provision of personal data referred to in art. 5.3. is mandatory for the fulfilment of the purposes set out in artt. 6.1.5.. Any refusal to provide such data causes the impossibility for the Controller to fulfil the legal obligations referred to in art 6.1.5. and, consequently, to provide the services referred to in artt. 6.1.1. and 6.1.2..
VI - DATA TRANSFER TO NON-EU COUNTRIES
11 – Subject’s data transfer to non-EU countries
11.1. This website may transmit some data to services located outside the European Union area, towards the US territory. The data transfer is authorized and strictly regulated by art. 45, par. 1 GDPR and by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016, because the the companies to which the data may be transferred adhere to the Privacy Shield.
11.2. Data will be never transferred to third countries which do not comply with the rules referred to in art.. 45 and following of Reg. (EU) 2016/679.
VII – PROVIDED DATA SECURITY
12 – Personal data security measures
12.1. This website processes users' data fairly and lawfully to GDPR as well to the current Italian legislation (D.Lgs. n. 196/2003 and subsequent amendments or additions), implementing appropriate technical and organizational measures suitable to risk mapped to avoid personal data breaches, leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data. The data processing is carried out by informatic tools and/or telematics, with organizational measures and according to logic strictly related to the purposes referred to in art. 6.
12.2. Other than the Controller, some categories of authorized people may have access to the data processing involved in the organization and management of the website (administrative staff, commercial staff, marketing staff, legal team, system administrators, etc.) or external entities in charge of outsourcing services on behalf of the Controller (such as technical service providers, hosting providers, IT companies, communication agencies) that are designated, if necessary or appropriate, as external data Processors.
VIII - COOKIES
13 - Cookies’ types
13.1. Please refer to the website’s cookies policy.
14 – Copyright
14.1. All texts, graphic components, sound files, videos, images, animation and more generally all the information hosted on this website are owned by Seven Salotti S.p.A. and protected by international Copyright law and by the other intellectual property law.
14.2. None of the contents referred to in the preceding subparagraph may be copied, modified or resold, in whole or in part, for profit.
14.3. Icons, logos and names of products displayed on the pages of this website are copyrighted by their respective owners or are anyway protected under trademark, patent and intellectual property laws.
X. USERS’ BROWSING ON THE WEBSITE
15 – Content of the website and disclaimer
15.1. Seven Salotti S.p.A. does not assume any responsibility for malfunctioning of the site www.arflex.it nor for the damages - of any nature - which may be caused to users by the access to the website or in any case by any contact with it, nor for that demages that may derive from third-party websites linked by this website or linked by social networks plugins incorporated in this website. Seven Salotti S.p.A. has no responsibility because links and sharing buttons constitute a facilitation for users, who can easily share contents or make other operations on the website through this buttons or plugins. Anyway Seven Salotti S.p.A. rejects any responsbaility about quality, contents and graphics of the websites reachable by these links, social buttons or plugins. Seven Salotti S.p.A. is neither responsible for information obtained by the user through the access to the websites linked to www.arflex.it. Therefore, the responsibles for the completeness and accuracy of information are the respective websites’ owners.
15.2. Seven Salotti S.p.A. has as main goal the ensuring that all the website’s contents are properly assessed and analyzed, as well as elaborated with accurancy and, if necessary, updated. At the same time, however, errors or omissions may occur: Seven Salotti S.p.A. declines, therefore, any form of liability for damages that users may suffer due to eventual errors, inaccuracies and omissions in the website’s contents, as well as due to the use of it done by third parties. Furthermore, Seven Salotti S.p.A. declines any form of liability for
damages that users may suffer due to errors, inaccuracies and omissions in third-party websites’ contents, reachable by links available on this website.
15.3. Any objects, products, software, etc., available on this website for download (e.g. technical files, commercial files, software, etc.), subject to laid down exceptions, are freely and free of charge available for the users under the conditions set out by Seven Salotti S.p.A., who reject any responsibility for the documents’ content, for the products’ characteristics nor for the functioning of software.